EPA conducted a virtual partial compliance evaluation (VPCE) of the Facility on February 25, 2021, to April 19, 2021, to determine compliance with Section 112(r) of the CAA, 40 CFR Part 68. On December 2, 2021, the EPA sent Respondent a Notice of Potential Violation and Opportunity to Confer letter. On January 19, 2022, the EPA responded to the documentation and information received from Respondent as a result of the opportunity to confer and articulated the EPA's position concerning Respondent's compliance. EPA determined eight findings of violation.